In the case of Simons v. Miami Beach First National Bank, Executor (1964), the Supreme Court was asked to determine whether a Florida law that allowed banks and trust companies to charge a fee for managing estates was constitutional. The plaintiff, Mrs. Simons, argued that this law violated her rights under the Due Process Clause of the Fourteenth Amendment because it did not provide an opportunity for judicial review or hearing before these fees were imposed. The court ruled in favor of Miami Beach First National Bank stating that there is no requirement under due process clause necessitating judicial determination of reasonableness prior to imposition and collection by corporate executor or trustee of compensation fixed by state statute for services rendered in administration of estate. This decision upheld Florida's statutory provision allowing such charges as long as they are reasonable and justifiable considering all relevant circumstances including size and character of trust property, responsibilities involved, nature and costs comparable services rendered by individual executors/trustees etc., thereby affirming constitutionality against challenge based on absence procedural safeguards like notice/hearing before imposing/collection these fees.

In the dissenting opinion for Simons v. Miami Beach First National Bank, Executor, Justice Harlan argued that the majority's decision to reverse and remand was not justified by existing legal precedent or sound reasoning. He contended that there was no clear error in the lower court's ruling which had found in favor of Miami Beach First National Bank as executor of a will challenged by Simons. The justice emphasized that it is not within the Supreme Court’s purview to second-guess factual determinations made by state courts unless they are clearly erroneous or involve constitutional issues. In this case, he believed neither condition applied; hence, he disagreed with his colleagues' decision to overturn a well-reasoned judgment from Florida's highest court based on their own interpretation of facts and circumstances surrounding this particular testamentary dispute.